The RFD-01 form is crucial for requesting a GST refund across various refund categories. How one applies for a refund under the GST law varies depending on different circumstances. Also, there are many distinctions which provide clarity on who is eligible to file applications for refunds under GST RFD-01 and RFD-01A in various scenarios within the GST registration framework.
In this blog, the main focus is on the GST RFD-01 form including its contents, filing time limits, where it originates, necessary prerequisites, and more.
Understanding GST RFD-01 and RFD-01A
Any taxpayer seeking a refund under the Goods and Services Tax system can utilise the GST RFD-01 form on the GST portal. It’s important to note that the offline application, RFD-01A, which was once available, is now obsolete. Refunds exceeding Rs.1,000 in value are eligible for processing.
GST RFD-01: Online Application for GST Refunds
GST RFD-01 serves as the online application for processing GST refunds. This form is electronically filed on the GST portal and can be used to claim refunds for various scenarios, including:
1. Taxes, cess, and interest paid for zero-rated supplies (excluding the export of goods with tax payment).
2. Excess cash paid into the electronic cash ledger.
3. Unutilised Input tax credit accumulated due to an inverted duty structure.
4. Excess tax payment resulting from the cancellation or termination of a service agreement or contract.
GST RFD-01 A: Manual Processing of GST Refunds
GST RFD-01 A, essentially a replica of GST RFD-01, was introduced only like a temporary solution up until the online facility for refund claims became available. It is the application form for manual processing of GST refunds, specifically notified for certain refund cases under GST system.
Application Process for GST RFD-01 and RFD-01A
To initiate the refund process, taxpayers need to log in to the GST portal, go to the ‘Refund’ tab, and select the ‘Application for Refund’ option. After selecting the type of refund, necessary details are filled out, mostly using an offline Excel tool, and submitted. The system generates an Acknowledgment Reference Number (ARN). Refunds are typically processed within 15 days from the date of application.
The processing officer, who can be a central tax authority or state/UT tax authority as notified, will intimate the refund status through the Acknowledgement in RFD-02 or RFD-03.
Applicants for RFD-01 and RFD-01A
In the context of filing applications in GST RFD-01 or RFD-01A, certain eligibility criteria and distinctions apply based on the nature of the supply and taxpayer involved.
1. Eligibility for Refund Claim of Accumulated ITC for Exports (Without Tax Payment)
For all cases, excluding deemed exports and supplies to Special Economic Zones, the taxpayer responsible for the supplies is entitled to claim a refund of accumulated Input Tax Credit related to exports without tax payment.
2. Refund of Excess Cash Balance or Excess Tax Payment
Any taxpayer is eligible to claim a refund for excess cash balance in the electronic cash ledger or tax paid in excess due to errors.
3. Refund by Unregistered Persons
Unregistered individuals can claim a refund for excess tax payment resulting from the cancellation or even termination of an agreement/ contract for supply of services.
4. Deemed Exports and SEZ Supplies
In cases of deemed exports and SEZ supplies, both the recipient and the supplier have the option to apply for a refund of taxes paid. Notably, for a specific invoice related to deemed exports, either the supplier or the recipient can apply for a refund. However, if the supplier initiates the refund process, a declaration from the recipient is required, confirming that they are not simultaneously claiming a refund for that particular supply.
Applicable Types of Refunds Through GST RFD-01 /01A in GST
Form RFD-01 serves as the gateway for processing various types of refunds under the Goods and Services Tax system. The applicable scenarios for filing GST RFD-01 or RFD-01A include:
1. IGST on Zero-Rated Supplies:
Exports of services (with tax payment) and supplies to Special Economic Zone (SEZ) units or developers.
2. ITC on Exports:
Goods or services exported under the letter of undertaking or bond, without tax payment.
3. Deemed Exports:
Refund claims for deemed exports filed by either the recipients or the suppliers.
4. Inverted Duty Structure:
Refund claims arising due to an inverted duty structure.
5. Excess Balance in Electronic Cash Ledger:
Refunds for the excess balance in the electronic cash ledger.
6. Excess Tax Payment:
Refunds for tax paid in excess due to errors.
7. Refund Due to Assessment, Provisional Assessment, Appeal, or Other Orders:
Refunds in cases where the assessment, provisional assessment, appeal, or any other order results in an overpayment.
8. Change in Tax Characterisation:
Refunds for tax paid for an intrastate supply that is later determined to be interstate, or vice versa.
9. Miscellaneous Cases:
Refunds falling under miscellaneous categories, as specified during the application.
10. Refund by Unregistered Taxpayers:
Unregistered taxpayers can claim refunds for excess tax payment due to the cancellation or even the termination of an agreement/contract for supply of services.
These comprehensive categories outline the diverse scenarios where taxpayers can utilise GST RFD-01 or RFD-01A to claim refunds under the GST framework.
Cases Exempt from Filing RFD-01 or RFD-01A for Refund Claims
While RFD-01 and RFD-01A cater to a wide range of refund scenarios under GST, there are specific cases where filing these forms is not required. The exemptions include:
1. Export of Goods with Export Duty Payment:
Refund claims for the export of goods that involve the payment of export duty are exempt from filing RFD-01 or RFD-01A.
2. IGST Paid on Goods Exports with Shipping Bill:
Exports of goods where IGST is paid, and the shipping bill is automatically considered as an application for refund. In such cases, RFD-01 or RFD-01A need not be separately filed.
3. Drawback Scheme Availment:
Cases where the supplier avails the drawback scheme of the CGST/SGST/IGST paid on the supplies, making them exempt from filing RFD-01 or RFD-01A for refund claims.
4. UN, Embassies, and Notified Persons:
Refund claims by entities such as the United Nations, embassies, and certain persons as notified, fall under exemptions from filing RFD-01 or RFD-01A.
5. Casual Taxable Persons/Non-Resident Taxable Persons:
Individuals falling under the category of casual taxable persons or non-resident taxable persons are exempt from filing RFD-01 or RFD-01A for refund claims.
These exemptions provide clarity on specific scenarios where alternative processes or considerations apply, and the standard filing of RFD-01 or RFD-01A is not necessary.
Conditions for GST Refund Application
To ensure a smooth process when applying for a refund of tax paid or accumulated Input Tax Credit without output tax payment in cases of zero-rated supplies and deemed exports, certain prerequisites must be met:
1. Filed GSTR-1 and GSTR-3B:
The applicant should have filed GSTR-1 and GSTR-3B for the month in which the zero-rated supplies and deemed exports were made.
2. Proper Filling of GSTR-1 and GSTR-3B:
Care must be taken to accurately fill GSTR-1 in the applicable tables, such as Table 6A for exports, Table 6B for supplies to SEZ units/SEZ developers, and Table 6C for deemed exports. GSTR-3B should be filled in Table 3.1(b) and filed in line with GSTR-1.
3. Invoice Details:
The applicant must have a list of invoices against which the refund is being claimed, and this list should be available during the application process.
4. Document Submission for Unregistered Persons:
For unregistered persons claiming a GST refund due to excess tax payment resulting from the cancellation or termination of an agreement or contract for the supply of services, the following documents need to be submitted:
· A statement containing invoice details (number, date, value, tax paid, etc.).
· Copy of the invoices.
· Proof of payment to the supplier.
· Copy of the agreement, registered agreement, or contract.
· Letter issued by the supplier for cancellation or termination.
· Details and proof of payment received from the supplier against cancellation or termination.
· Certificate from the supplier stating payment of tax, non-adjustment through credit note, and no claim for a refund.
· In certain cases, a certificate from a Chartered Accountant/Cost Accountant is required.
5. Compliance with Notification No: 26/2022:
Adherence to the requirements outlined in Notification No: 26/2022 for unregistered persons claiming a GST refund.
Time Limit and Filing Frequency of GST RFD-01
Ensuring adherence to timelines and filing frequencies is crucial when dealing with RFD-01 for GST refunds. Mentioned below are the key considerations:
1. Time Limit for Refund Claim:
Refund claims must be made within two years from the relevant date specified in RFD-01.
2. Monthly Mandatory Filing:
RFD-01 must be mandatorily filed on a monthly basis for the following cases:
· Refund claims for zero-rated supplies.
· Refund claims in cases of an inverted duty structure.
· Refund claims for deemed exports.
· Refund of excess balance in the electronic cash ledger.
3. Multiple Tax Periods in One Financial Year:
RFD-01 can be filed for multiple tax periods in a single refund application, provided they fall within the same financial year.
4. Supply of Goods to SEZ:
For the supply of goods to SEZ units or SEZ developers, the supplier must file RFD-01 once the receipt of goods is confirmed by authentication from a specified officer of that zone.
5. Supply of Services to SEZ:
In the case of the supply of services to SEZ units or SEZ developers, the supplier is required to file RFD-01 once evidence of service receipt is confirmed by authentication from a specified officer of that zone.
6. Refund by Unregistered Taxpayer:
For a refund by an unregistered taxpayer, the applicant should calculate the two-year due date for filing a refund application from the date of issuance of the cancellation letter for the contract.
Final Thoughts
GST RFD-01 is an important form for facilitating seamless and timely refund processes within the Goods and Services Tax framework. With a stringent two-year time limit from the relevant date, this monthly filing requirement is imperative for various scenarios, including zero-rated supplies, inverted duty structures, deemed exports, and excess cash ledger balances. The flexibility to file for multiple tax periods within a financial year adds convenience. Specific procedures for supplies to Special Economic Zones further enhance the precision of the refund system. Overall, RFD-01 plays a crucial role in reforming refund claims and maintaining compliance within the dynamic landscape of GST regulations.
